Why the European Accessibility Act affects more businesses than many think
Since 28 June 2025, the European Accessibility Act has applied across the EU, including in Sweden through the Act on the accessibility of certain products and services. It means that e-commerce, banking services and digital interfaces must be accessible to people with disabilities. Many companies assume the rules only concern the public sector, but the law also covers private businesses that serve consumers.
A year after the law took effect, supervision is increasing and the first legal cases in Europe have begun. This article explains what the law requires, who is covered and how your business can make sure it meets the requirements.
What is the European Accessibility Act?
The European Accessibility Act (Directive (EU) 2019/882) is transposed into Swedish law through the Act (2023:254) on the accessibility of certain products and services. Its aim is to make key products and services usable by everyone, regardless of ability, and to create consistent rules across the internal market.
The requirements are based on the European standard EN 301 549, which in turn references the international WCAG guidelines at Level AA. In practice, this means websites and apps must be perceivable, operable, understandable and technically robust, so that they work with tools such as screen readers, keyboard navigation and magnification.
Which products and services are covered?
The law targets a range of consumer products and services. Services in scope include e-commerce, consumer banking services (such as payment services and accounts), electronic communications services and access to digital media services. Products in scope include computers, smartphones, payment terminals, ATMs and ticketing machines.
For e-commerce, the requirements apply regardless of where the business is established, as long as the service is directed at consumers in the EU. A Swedish company selling goods or services online is therefore normally covered, as are foreign operators targeting Swedish customers.
Who supervises the rules in Sweden?
The Swedish Post and Telecom Authority (PTS) is the market surveillance authority for the products and is responsible for supervising several of the services, including e-commerce, banking services and electronic communications services. PTS also has a coordinating role where a matter concerns more than one area of supervision. Businesses that fail to meet the requirements can be ordered to remedy the shortcomings and, ultimately, face penalties.
Exemptions and limitations
Microenterprises providing services
Microenterprises – businesses with fewer than ten employees and an annual turnover or balance sheet total below EUR 2 million – are exempt from the requirements when it comes to services. However, the exemption does not automatically apply to those who manufacture or sell products covered by the law.
Disproportionate burden
Businesses larger than microenterprises may, in certain cases, argue that full accessibility would impose a disproportionate burden, for example if the adaptation would fundamentally alter the service or entail unreasonable costs relative to the benefit. This is not a blanket exemption: the assessment must be documented, notified to the supervisory authority and reviewed regularly.
Transitional rules
Some transitional provisions soften the impact. Service contracts concluded before 28 June 2025 may continue unchanged until 28 June 2027. For payment terminals and ATMs lawfully in use before 28 June 2025, a transitional period runs until the end of their useful life, but no longer than twenty years from when they were first put into use.
Practical example: an online shop
Suppose a mid-sized Swedish company runs an online shop. From 28 June 2025, the website and any app must meet the accessibility requirements: text must have sufficient contrast, all functions must be reachable by keyboard, images must have alternative text, and the checkout flow must work with a screen reader. The company must also describe, in writing, how the service meets the accessibility requirements and make that information available to customers. Simply relying on the platform provider having “handled accessibility” is not enough – responsibility rests with the party providing the service.
Common mistakes companies make
A common mistake is treating accessibility as a one-off project. In practice, every update to a website, app or checkout flow requires accessibility to be maintained. Another mistake is a lack of documentation: the law requires businesses to be able to show how their service meets the requirements. Finally, many confuse the automatic microenterprise exemption with the option to invoke disproportionate burden, which is considerably more demanding and must be documented and notified.
Recommended actions
Start by mapping which of your digital services and products are covered. Carry out an accessibility audit of your website and app against EN 301 549 and WCAG Level AA, prioritising the most critical issues in checkout and login flows. Prepare the statutory information on how the service meets the requirements. Review contracts with vendors and agencies so that responsibility for accessibility is clearly regulated, and put in place procedures ensuring new features are tested for accessibility before launch.
Frequently asked questions
Does the law apply if we only sell to businesses?
The law is primarily aimed at services and products directed at consumers. Pure business-to-business sales normally fall outside its scope, but the line can be difficult to draw if you also serve private individuals. Where there is uncertainty, a legal assessment should be made.
What does WCAG Level AA mean in practice?
It is a set of criteria that make digital content usable by more people, for example sufficient colour contrast, text alternatives for images, the ability to navigate by keyboard, and content that works with assistive tools such as screen readers.
What happens if we do not meet the requirements?
The supervisory authority can require corrective action and, ultimately, impose penalties. Beyond that there is a business risk: inaccessible services shut out customers and can damage your brand.
Conclusion
Accessibility is no longer an optional ambition but a legal requirement for many businesses. The Act on the accessibility of certain products and services has applied since 28 June 2025, supervision is tightening and the first cases in Europe have begun. Businesses that map their services, audit them against the standard and document their work reduce both the legal risk and the risk of losing customers. At Lawgent, we help companies interpret the accessibility law and turn it into concrete action, from legal assessment and contracts to documentation and internal procedures. Get in touch if you want to make sure your digital services meet the requirements.
